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that the gifts were valued based upon what one would pay at a
thrift shop or rummage sale.
As evidence to substantiate their noncash gifts, petitioners
introduced an itemized list of what petitioner testified to be
the value of the gifts that they had claimed on their return.
Petitioners’ list gave only a general description of the items
that they donated. One of the gift dates on petitioners’ list,
April 17, 2001, is not listed on the return. Petitioners claimed
on their return $500 as the value for each of 10 gifts to the
Salvation Army. Aside from the fact that the amounts on
petitioners’ list appear to be inflated, none of them are valued
by petitioners at $500. Each of the three gifts to Sun Cities
Animal Rescue is reported on the return at a value of $500, but
on the list the gifts are valued at $736, $240, and $388. The
values of the two Goodwill donations on the list, likewise, do
not jibe with the amounts on the return.
While the Court believes that petitioners actually donated
the items on the list, petitioners offered no corroborating
evidence that the method they used to value the property was
accurate. The Court finds that petitioners have failed to prove
the value of their contributions. The Court further finds, using
its judgment, that the fair market value of the donated property
was $2,000. Petitioners are entitled to a deduction in that
amount. See Cohan v. Commissioner, 39 F.2d 540, 543-544 (2d Cir.
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